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The U.S. Department of Commerce (DOC) recently announced the initiation of administrative reviews of anti-dumping (AD) and countervailing duty (CVD) measures applicable to certain products imported from Vietnam, including solar cells, raw honey and woven bags.
The reviews are being conducted based on requests from interested parties and may result in the recalculation of the duty rates applicable to exporting companies for the respective review periods.
U.S. Reviews Duties on Three Groups of Products from Vietnam
According to the published information, the DOC is conducting reviews covering the following cases and periods:
Solar Cells
For anti-dumping duties, the case bears the number A-552-841, with the period of review (POR) running from December 4, 2024 to May 31, 2026.
For countervailing duties, the case bears the number C-552-842, with the POR running from October 4, 2024 to December 31, 2025.
This is a case previously investigated by the DOC concerning crystalline silicon photovoltaic cells, whether or not assembled into modules, from Vietnam, Cambodia, Malaysia and Thailand. The DOC issued its final determinations in April 2025, finding dumping and countervailable subsidies with respect to products from Vietnam.
Raw Honey
The DOC is conducting an administrative review of anti-dumping duties in case A-552-833, covering the POR from June 1, 2025 to May 31, 2026.
Woven Bags
For woven bags, the administrative review of anti-dumping duties bears the number A-552-823, covering the POR from June 1, 2025 to May 31, 2026.
The list of companies subject to the reviews is expected to include producers and exporters that exported products covered by the respective cases to the U.S. market during the corresponding review periods.
Companies Should Proactively Confirm Their Export Status
According to the initiation notices, companies listed for review that did not actually export products covered by the respective cases to the United States during the POR must notify the DOC within 30 days from the date of publication of the initiation notices. Based on the current schedule, this deadline falls around September 10, 2026.
Accurately confirming export status is important because DOC administrative reviews are intended to determine the actual amount of AD or CVD owed on entries made during the review period. According to the DOC, the results of an administrative review may also be used to establish the cash deposit rate applicable to future entries.
Following initiation, the DOC is expected to select mandatory respondents based on export data provided by U.S. Customs and Border Protection (CBP). The selection is expected to be made within 35 days of publication of the initiation notices, with priority generally given to companies with larger export volumes.
For parties that requested the reviews, U.S. law also allows requests for review to be withdrawn within a specified period. Based on the current information, parties may withdraw their requests for review within 90 days from the date of publication of the initiation notices.
Review Results Expected in June 2027
The DOC is expected to complete the reviews and issue its determinations no later than June 30, 2027. During the process, the investigating authority will continue to request necessary information from the parties, including information relating to surrogate country selection in cases involving non-market economy methodology, Quantity and Value (Q&V) questionnaires, and questionnaires for mandatory respondents.
For AD cases involving Vietnam, the surrogate value factor may be particularly important. The DOC continues to treat Vietnam as a non-market economy (NME) for purposes of its AD methodology and maintains surrogate country selection materials for investigations and reviews involving Vietnam.
Companies selected as mandatory respondents should pay particular attention to the deadlines for responding to the DOC’s questionnaires. Failure to provide complete and accurate information, or failure to respond within the prescribed deadlines, may directly affect the determination of a company’s dumping margin or subsidy rate.
What Should Vietnamese Companies Prepare?
An administrative review is not a new investigation into whether dumping or subsidization exists. Instead, it focuses on determining the applicable duty rates for transactions made during the POR. The DOC explains that administrative reviews are conducted periodically for AD and CVD orders that remain in effect.
Accordingly, Vietnamese producers and exporters subject to the reviews should proactively review their export data for the entire relevant period and prepare transaction records, pricing and cost data, production volumes, and other information relating to their production and export activities.
For companies selected as mandatory respondents, it is particularly important to establish a data system that can reconcile accounting records, export documentation, customs data, and information submitted to the DOC. Companies should also closely monitor subsequent notices concerning questionnaires, response deadlines, supplemental information requests, and other procedural milestones.
As the United States continues to maintain multiple trade remedy measures affecting goods from Vietnam, full and timely participation in administrative reviews is directly relevant to the duty rates that companies may be required to pay on entries during the POR, as well as the cash deposit rates applicable to subsequent transactions.
To protect their legitimate interests, manufacturers and exporters should familiarize themselves with the procedure and actively contact Vietnam Antidumping Law Firm specializing in anti-dumping and trade remedy for timely assistance.
ASL Law is a leading full-service and independent Vietnamese law firm made up of experienced and talented lawyers. ASL Law is ranked as the top tier Law Firm in Vietnam by Legal500, Asia Law, WTR, and Asia Business Law Journal. Based in both Hanoi and Ho Chi Minh City in Vietnam, the firm’s main purpose is to provide the most practical, efficient and lawful advice to its domestic and international clients. If we can be of assistance, please email to [email protected].
ASL LAW is the top-tier Vietnam law firm for Anti-dumping & countervailing. If you need any advice, please contact us for further information or collaboration.
